Here is my prepared oral statement regarding the proposed renewal of the MOU with Cyprus:
I’m speaking on behalf of IAPN and PNG, which represent the small businesses of the numismatic trade. In many ways, this hearing is a much greater test for CPAC than for coin collectors. Prior committees have twice recommended against import restrictions on coins for good reason. Yet, there will certainly be pressure to change course and to fall into line with the State Department’s controversial 2007 decision to impose import restrictions on “coins of Cypriot type.”
Each Committee member must ask themselves whether they can do so in good conscience after considering these undisputed facts, particularly because the restrictions at issue can lead to civil or criminal liability for American collectors and the American small businesses of the numismatic trade, including seizure of their coins:
1. Coins were evidently placed on the designated list on the orders of former Undersecretary Nicholas Burns – now of Harvard University’s Kennedy School-- as a “thank you” to Cypriot advocacy groups which had given him an award;
2. Jay Kislak, CPAC’s former chair, has stated under oath that the State Department misled Congress and the Public about CPAC’s vote against import restrictions on coins;
3. In 2007, the AIA claimed that Cypriot coins “rarely circulated” to justify restrictions on “coins of Cypriot type.” However, a top Cypriot official has admitted that “It is true that Cypriot coins shared the same destiny as all other coins of the ancient world. As a standard media of exchange they circulated all over the ancient world due to their small size, which facilitated their easy transport…” Moreover, this view has substantial scholarly support, as set forth in our papers;
4. The CPIA requires less drastic remedies to be tried first before import restrictions are imposed, but Cyprus has no coherent regulatory scheme for metal detectors and even allows British tourists to bring them to the Island;
5. Restrictions imposed on unprovenanced “coins of Cypriot type” only discriminate against American collectors and the small businesses of the numismatic trade; such coins may be shipped from abroad to anywhere but the USA, including Cyprus.
Moreover, there is no good reason to renew the MOU for yet another 5 years. Cyprus has already had the benefit of restrictions since 1999 on ethnological artifacts and 2002 on archaeological artifacts. Yet, a Swiss scholar reports most looted material goes to wealthy Greek Cypriot collectors, and not as has been maintained to collectors abroad. In addition, all this appears to be done with the full knowledge and acquiescence of Greek Cypriot authorities. Under the circumstances, why should the US burden its own citizens and small businesses with such restrictions? To do so will only reward Cypriot authorities for their own hypocrisy and thus make a mockery of the supposed purpose of such MOU’s to protect archaeological context.
In sum, please give heed to the 77% of the public comments posted on the regulations.gov website opposed to import restrictions on coins. Thank you.